United States v. Montrell Dupriest, 794 F.3d 881

DuPriest pleaded guilty in 2006 to using a telephone to facilitate drug trafficking; Judge Stadtmueller sentenced him to 48 months imprisonment and 12 months supervised release.
After release, police arrested DuPriest with a pistol and marijuana; state charges were dismissed for federal prosecution; he received an 18-month state supervised-release revocation sentence.
DuPriest pled guilty to being a felon in possession of a firearm under 18 U.S.C. § 922(g); Judge Adelman sentenced him to 33 months plus 24 months supervised release, to run concurrently with the state revocation sentence.
At the federal supervised-release revocation hearing, Judge Stadtmueller imposed an 18-month revocation sentence (nine months concurrent, nine months consecutive); the government conceded on appeal that 18 months exceeded the statutory maximum and the case was remanded for resentencing.
On remand, Judge Stadtmueller imposed the statutory maximum 12-month revocation term, with six months concurrent and six months consecutive, explaining the need for incremental punishment given DuPriest’s recidivism and the seriousness of the firearm offense.
DuPriest appealed, arguing the district court failed to consider relevant 18 U.S.C. § 3553(a) factors and that the sentence violated the parsimony principle; the government defended the adequacy of the district court’s explanation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court failed to consider § 3553(a) factors before resentencing	DuPriest: court did not adequately consider nature of arrest, history/characteristics, deterrence, and public protection	Government: transcript shows the court thoughtfully addressed § 3553(a) factors and provided adequate reasons	Court: Affirmed — district court sufficiently considered § 3553(a) factors and gave adequate explanation
Whether the sentence violated the parsimony (not greater than necessary) principle	DuPriest: consecutive portion and overall sentence are greater than necessary	Government: sentence tailored to repeat offender; explanation shows necessity	Court: Affirmed — explanation supports that sentence was not greater than necessary

United States v. Jones, 774 F.3d 399 (7th Cir. 2014) (explains deferential standard and that courts need not recite § 3553(a) in checklist form)
United States v. Robertson, 648 F.3d 858 (7th Cir. 2011) (describes narrow review applied to supervised-release revocation sentences)
United States v. Kizeart, 505 F.3d 672 (7th Cir. 2007) (comparison to limited review afforded prison disciplinary sanctions)